Should the reducing factor of 0.2 for applying the emergency planning notification threshold planning quantities (TPQs) for non-reactive solid extremely hazardous substances (EHSs) in solution also be used when applying the reporting thresholds for MSDS Reporting under section 311 and Hazardous Chemical Inventory reporting under section 312 of EPCRA (40 CFR 370)?
No. Facilities must not use the reduction in quantity on-site to determine the “amount present at one time” for reporting under 40 CFR 370.10. Submission of MSDSs and an on-site inventory of hazardous chemicals are needed for all forms of chemicals to help emergency responders assess how to respond to an emergency release or fire when the responders are on-site. In particular, responders need the amounts, manner of storage and locations of the chemical on-site, the chemical and physical properties, hazard ratings, toxicity information and incompatibilities of the chemical, as well as measures needed to contain the spill or fire at the facility in order to know how to respond to an emergency. In addition, they need to know what type of protective equipment is needed to protect them from exposure, not only airborne, but also dermal exposure. Emergency planning notification under section 302 is primarily focused at identifying those facilities whose accidental releases pose risks to the surrounding community outside of the facility so that LEPCs can develop emergency plans that identify the location and number of affected populations, evacuation or shelter-in-place procedures, etc.